19 F.4th 1035
8th Cir.2021Background
- A shooting in an apartment complex parking lot injured three men; officers identified a Unit 1 apartment with a security camera pointed at the lot where some residents (including Christina Haney) lived with Martece Saddler.
- Detective Matt Dunn interviewed witnesses, reviewed business surveillance corroborating the shooting, and learned Haney drove a Buick seen leaving the scene; investigators also learned of a social‑media dispute involving Haney and one victim’s relative.
- Dunn prepared an affidavit and obtained a warrant to search Unit 1 for, among other things, camera devices, storage devices, social‑media devices/storage, and items related to aggravated assault; the warrant was later found to include unconstitutionally overbroad clauses (an issue not before the court on appeal).
- Officers executed the warrant; Officer Jorgensen searching a bedroom closet moved clothes looking for SIM‑sized storage devices and observed and removed a short, sawed‑off shotgun, then seized it along with phones, a laptop, and other items.
- Saddler pleaded guilty to being a felon in possession of a firearm but reserved the right to appeal the denial of her suppression motion, arguing (1) the affidavit failed to establish probable cause, (2) the Leon good‑faith exception did not apply, and (3) the shotgun was not lawfully seized under the plain‑view doctrine.
- The district court denied suppression; the Eighth Circuit affirmed, reviewing factual findings for clear error and legal conclusions de novo.
Issues
| Issue | Plaintiff's Argument (Saddler) | Defendant's Argument (Government) | Held |
|---|---|---|---|
| Probable cause for warrant to search Unit 1 (esp. devices/social‑media storage) | Affidavit lacked sufficient substance/detail to show a fair probability evidence would be found in Unit 1 | Affidavit tied Haney/Unit 1 to the shooting (witness statements, video, social‑media dispute, camera pointed at lot); supported search for devices and storage | Affidavit provided a substantial basis for probable cause to search for devices/social‑media storage; magistrate’s finding entitled to deference |
| Good‑faith (Leon) exception to exclusionary rule for execution of overbroad warrant | Warrant was so facially overbroad that no reasonable officer could rely on it; exclusion required | Officer Dunn’s reliance on a magistrate‑issued warrant was objectively reasonable given the affidavit, magistrate’s signature, and investigative context; any drafting overbreadth was negligent, not reckless | Good‑faith exception applied; executing officers reasonably relied on the warrant despite some overbroad language |
| Plain‑view seizure of sawed‑off shotgun | Officers were not lawfully present (warrant invalid); gun’s incriminating nature was not immediately apparent from the shelf and removing it violated Hicks | Officers were lawfully present based on objectively reasonable reliance on warrant; searching closet for SIM‑size storage devices made removal reasonable; once removed, gun’s incriminating nature was immediately apparent | Seizure upheld under plain‑view: officers lawfully present, incriminating character immediately apparent after removal, and lawful access existed |
Key Cases Cited
- Warden v. Hayden, 387 U.S. 294 (Sup. Ct. 1967) (probable cause to seize "mere evidence" is sufficient when it will aid in apprehension/conviction)
- United States v. Leon, 468 U.S. 897 (Sup. Ct. 1984) (good‑faith exception to exclusionary rule; exceptions where reliance is unreasonable)
- Maryland v. Garrison, 480 U.S. 79 (Sup. Ct. 1987) (particularity requirement prevents wide‑ranging exploratory searches)
- United States v. Szczerba, 897 F.3d 929 (8th Cir. 2018) (good‑faith analysis where warrant omitted items listed in affidavit)
- United States v. O’Dell, 766 F.3d 870 (8th Cir. 2014) (probable cause standard: fair probability that evidence will be found)
- United States v. Grant, 490 F.3d 627 (8th Cir. 2007) (deference to magistrate’s probable‑cause determination; common‑sense review)
- Coolidge v. New Hampshire, 403 U.S. 443 (Sup. Ct. 1971) (plain‑view seizure principles)
- Arizona v. Hicks, 480 U.S. 321 (Sup. Ct. 1987) (manipulation of items in plain view may be unlawful when unrelated to authorized intrusion)
- Herring v. United States, 555 U.S. 135 (Sup. Ct. 2009) (exclusionary rule applies only for deliberate, reckless, or grossly negligent police conduct)
- United States v. Arredondo, 996 F.3d 903 (8th Cir. 2021) (plain‑view seizure elements)